(1.) Both the tax appeals (for the assessment year 2003-04 and the assessment year 2004-05) essentially concern identical question of fact and law and, hence, are decided by a common order. The facts and other details are taken for the purpose of adjudication from Tax Appeal No. 756 of 2013. Following is the substantial question of law raised for our consideration by the Revenue in Tax Appeal No. 756 of 2013 challenging the order of the Income-tax Appellate Tribunal ("the Tribunal" for short) dated April 18, 2013:
(2.) We have heard learned counsel Shri Manish Bhatt for the Revenue and Shri Bandish Soparkar for the assessee-respondent in both the matters.
(3.) The question pertains to the deletion of the addition of interest of Rs. 87,35,694 in the following factual background.